On March 12, 2025, the SEC Division of Corporation Finance issued a no-action letter to Latham & Watkins in response to a request for interpretive guidance on Rule 506(c) of Regulation D under the Securities Act of 1933, as amended. Rule 506(c) permits the use of general solicitation in Rule 506 offerings if all of the purchasers are accredited investors and if the issuer takes “reasonable steps to verify” the accredited investor status of purchasers. The no-action letter proscribes a process through which an issuer could reasonably conclude that it has taken reasonable steps to verify a purchaser’s accredited status when the purchaser agrees to a certain minimum investment amount that satisfies the asset threshold required under the “accredited investor” definition (i.e., $200,000 for a natural person or $1 million for an entity) and provides written representations regarding such investment. This guidance opens the door for more private fund managers to avail themselves of the Rule 506(c) exemption and more actively fundraise through the use of general solicitation, assuming they have established relevant policies and procedures to rely on the conditions in the no-action letter.